For manufacturers of electrical and electronic equipment (EEE), the crossed-out wheelie bin symbol is often seen as nothing more than a regulatory formality. In reality, it is a key instrument of EU waste policy, linking product design, consumer behaviour and end-of-life management within the circular economy. 

The symbol is required by Directive 2012/19/EU on waste electrical and electronic equipment (WEEE). Manufacturers placing electrical and electronic equipment on the EU market must ensure that products are marked in accordance with the following provisions: 

• Article 14 of the Directive (information for users) 
• The technical labelling standard EN 50419 

This obligation is not merely administrative in nature. It ensures that environmental information reaches the end user directly at the point where decisions about disposal are made. 

Why Most Symbols These Days Contain a Black Bar 

Many products have a solid black bar under the wheelie bin symbol. This detail has a specific legal meaning: the bar indicates that the product was placed on the EU market after 13 August 2005, the cut-off date specified in the original WEEE Directive, which makes it possible to distinguish between the following products: 

• Historical WEEE that was placed on the market before this date (for which the end user has the responsibility of collection and recycling)
• New WEEE that was placed on the market after this date (for which the producer has all related obligations, being the first one to put the product onto the market in a specific country) 

This distinction remains important for authorities and PROs, as it helps to determine financial responsibility for waste disposal. 

A Direct Means of Communication for End Users 

The crossed-out wheelie bin is one of the EU’s most direct means of communication in the field of environmental protection. It is intended to inform consumers that electrical and electronic equipment must not be disposed with unsorted waste. By stipulating that the label must be visible, legible and durable, the directive ensures that private end users as well as professionals understand that they must: 

• dispose equipment via separate collection systems 
• avoid unsorted and mixed waste 
• return products to authorised WEEE collection points 

This simple visual signal is not a sign that the product and the producer are registered and compliant, a frequent misunderstanding we are facing in our daily operations.

Why the Symbol Is Important For Producers 

From a systems perspective, correct labelling directly contributes to the efficiency of collection and material recovery. In this way, the symbol not only supports compliance with legal requirements, but also operational efficiency along the entire waste management chain. Clear information for end users helps to:

• reduce the amount of WEEE ending up in residual waste 
• increase recovery rates for valuable materials such as copper, aluminium and rare earth elements 
• limit environmental and health risks from hazardous components 
• improve overall collection rates for WEEE, an important performance indicator under EU law 

While authorities carry out awareness campaigns to improve separate collection, product labelling remains the only information permanently affixed to the device itself – it is therefore a fundamental element of the WEEE system. 

Should you require further information about the crossed-out bin icon or your obligations as a producer under EPR regulations, do not hesitate to reach out to us via our Quick Obligation Check.

Batteries may be small, but the regulatory changes around them are significant. Since January, the new EU Battery Regulation has begun reshaping compliance across Europe, with its key provisions officially binding as of August 2025. For manufacturers and distributors, this isn’t just a legal update – it’s a shift toward new reporting structures, revised categories and adjusted processes. So what does this transformation actually mean in day-to-day business terms? 

Until now, batteries have been reported primarily according to their chemistry and weight. With the new regulation, the focus is now more on the actual use of the battery in the respective device or area of application. The new classification comprises five categories: 

• Portable batteries (≤ 5 kg) – e.g. in mobile electrical devices 
• Industrial batteries (> 5 kg) – for industrial applications
• LMT batteries (Light Means of Transport) – e.g. for e-bikes or e-scooters 
• SLI batteries (Starting, Lighting, Ignition) – typically for vehicles with combustion engines 
• EV batteries – for electric and plug-in hybrid vehicles 

A good example is the rechargeable lithium-ion battery: it can be found in all five categories – from smartphones and power tools to electric cars. So it is not just the battery itself that is decisive for reporting, but what it is used for. 

Adjustments in Reporting: New Categories in the Reporting Systems 

To reflect this differentiation, the European take-back systems (PROs – Producer Responsibility Organisations) have revised their reporting categories. The PRONEXA reporting tool (CDM platform) already reflects these changes. Companies will see the new categories in their monthly volume reports from January onwards and will have to allocate their battery sales volumes accordingly. 

In practice, this means: 

• Products that were previously reported under old categories must be reassigned. 
• Correct classification according to application is crucial for legally compliant reports. 

Are There Any New Legal Obligations? 

For many battery manufacturers and distributors who are already registered, the basic obligations remain the same. Nevertheless, there are specific new requirements for action in individual countries. 

1. Example Germany: Some existing battery contracts with take-back systems must be resigned or amended to comply with the new regulatory requirements. 
2. Example Denmark: There is an important change for foreign manufacturers here: they must now also register and report batteries – both as spare parts and integrated into electrical appliances. 

Regulations have also been tightened in other countries where previously no reporting obligation existed for foreign producers. Companies must now also register and report there– in line with the regulations in other EU countries. 

New Price Lists and Conversion of Existing Reports 

With the new Battery Regulation, many PROs have also adjusted their price structures. This has several practical consequences: 

• Manufacturers must transfer their previously reported products to the new categories in order to be able to report correctly from January onwards. 
• In some countries, new registration requirements are being introduced for companies that were not previously subject to reporting obligations. 
• Existing contracts with take-back systems – for example, in Germany – may need to be updated. 

Conclusion:
Review Your Processes and Adjust Reports Now 

The new EU Battery Regulation does not introduce entirely new obligations, but rather a more precise, application-oriented system – with direct implications for reporting, contract structures and national registration requirements. 

Companies should: 

• assign their product portfolios to the new battery categories 
• review national specifications 
• review existing contracts and registrations 

If you are unsure about the new EU Battery Regulations and its impact on you as a producer, it is advisable to contact your responsible PRONEXA Compliance Specialist directly.
If you are not a PRONEXA customer yet, please use the QUICK OBLIGATION CHECK.

PRONEXA Compliance Specialists support companies in identifying necessary adjustments and implementing them in a legally compliant manner.

An important milestone will be the publication of the Design for Recycling (DfR) guidelines by January 2028. These guidelines will define when packaging is officially considered recyclable, and according to the PPWR, this requirement extends far beyond theoretical standards.  

Packaging must:  

• be sortable in existing waste streams
• be recyclable in efficient industrial processes, 
• produce secondary raw materials that can replace virgin materials. 

At the same time, recyclable packaging will be rewarded with lower EPR fees through eco-modulation, while formats that are difficult to recycle will be subject to higher costs. As existing forms of eco-modulation already show, implementing these changes will be challenging in practice and very difficult to monitor.  

2030: Recyclability as a Market Requirement 

From 2030, packaging must be at least 70% recyclable to enter the EU market. Stricter rules, including the Recycled at Scale (RaS) requirement from 2035, will tie recyclability to real recycling rates. Additional measures like single-use plastic bans and reuse targets will change packaging and infrastructure further. 

Mandatory Recycled Content in Plastics 

The PPWR sets required recycled content levels for plastic packaging:  

• 2030, ranges between 10% and 35%, based on plastic type,  
• 2040, rising to 25%–65%.  
• Exceptions cover some medical or pharmaceutical packaging, and packaging with less than 5% plastic. These rules aim to drive demand for high-quality recyclates in critical uses. 

By 2026, the European Commission will set standard rules for calculating and verifying recycled content to improve market transparency and regulation enforcement. Eco-modulation means packaging with higher recycled content may cost less, depending on national implementation.  

Recycled at Scale (RaS): Integrating Design With System Effectiveness 

The RaS requirement introduces an additional critical aspect. Packaging qualifies as recyclable only if it is recycled to a substantial degree within designated material streams. This criterion establishes a direct connection between product design and the real capabilities and performance of recycling systems. Although some requirements are still far off, current reports for packaging already demand recycling data and evidence. 

Packaging Data That You Are Required to Report 

We assist you with your packaging reporting and submit your regular reports to the PROs or authority bodies. In this report, you list the amount of packaging you introduce to the market or country. The authority uses this information to calculate the material recycling rates (%) of recycled packaging. After submitting the report with material and packaging amounts, an invoice will be generated. 

Reporting to PROs or Authority Bodies  

Report packaging volumes in kilograms for all packaging types you put on the market, specifying if they are for households or other uses. Include packaging made from these materials in your report:  

• cardboard/paper,
• wood,
• glass,
• metal (steel or aluminium),
• plastics and 6. other packaging materials (such as ceramics and textiles). 

Recyclability and Reporting by Recycling Grade
(e.g., Denmark, Sweden, Finland, France, UK)  

A number of countries have established graded recycling systems, featuring tiered fees according to the recyclability of packaging. These fees range from green (lower rates) to amber and red (higher rates).  

In Sweden, both rigid and flexible mono-material plastic packaging can be easily identified through modern sorting technology, which streamlines material separation and improves downstream recyclability. This results in higher recycling rates and significant cost reductions for customers. Moreover, bonuses are awarded for paper and cardboard that are not laminated or coated, as these materials dissolve more readily during recycling, especially within paper mills. 

To sum up, every EPR fee takes into account that mono-materials are simpler to sort and recycle, making them ideal for creating secondary raw materials. Regulations encourage replacing virgin materials with recycled alternatives. Additionally, colourinfluences sorting and recycling processes, which is why some countries require reporting by clear or coloured packaging. 

By adopting Design for Recycling (DfR) principles in your packaging, your organisation can fulfil regulatory obligations and lower expenses. 

Reporting Requirements for Single-Use Plastic (SUP) Products 

For packaging reports in Nordic countries like Sweden and Finland, companies must identify any single-use plastic items in their product portfolio. If your company has single-use plastic products (e.g. plastic carrier bags), you are required to report their quantities in your SUP submission.  
Future updates will cover more details on single-use plastics and packaging, including EPR stream information. 

Need Help With Complex Reports Across Different Countries?  

Contact us via our QUICK OBLIGATION CHECK to learn which obligations apply.
We provide consulting and operational support for importers, producers, and resellers of packaging and packaged goods. 

It’s a striking figure: every EU citizen generated 177.8 kg of packaging waste in 2023, according to Eurostat. The environmental and economic implications are impossible to ignore – escalating resource consumption, loss of valuable materials, and rising regulatory pressure on businesses. 

The EU’s response is the Packaging and Packaging Waste Regulation (PPWR). Unlike a directive, this regulation applies directly across all Member States since 11.02.2025, while most of its obligations and legal requirements will kick in as from 12 August 2026, leaving no room for national interpretation or delay. Its mission is clear: prevent unnecessary packaging, drive reuse, and significantly increase recycling rates. By 2030, at least 70% of all packaging waste must be recycled, with ambitious material-specific targets for plastics, paper, glass, metals, and wood. 

Are You a “Producer” Under the PPWR? 

But there is one aspect many companies underestimate: The PPWR introduces a new, much clearer definition of who is the “producer”. And this matters — because the “producer” becomes the central responsible party for compliance and Extended Producer Responsibility (EPR). 

This is where many businesses will be affected – even those who never considered themselves packaging producers before. The New PPWR Definition of “producer” (Art. 3.15) is defining a producer as the economic operator who first makes packaging or a packaged product available on the market of a Member State, whether as: 

• a manufacturer
• an importer 
• a distributor 
• an e-commerce operator 
• a brand owner 
• or a contract giver 

The objective is simple: every packaging unit should have one clearly identifiable responsible producer. 

The Contract Giver Becomes the Producer

The contract giver is automatically the producer – that is one of the most impactful changes. If you have packaging or packaged products manufactured under your own name or trademark, you are considered the producer, even if: 

• another company physically manufactures the product, 
• another brand name appears on the packaging, 
• production happens outside the EU. 

This means, the contract giver becomes legally responsible for the packaging. All EPR obligations fall to them, including fees, reporting, design requirements, and compliance documentation. 

Why This Matters for Your Business 

The new definition of a manufacturer under PPWR includes any natural or legal person who manufactures packaging or packaged products – or the customer who commissions this manufacturing. As a result, the roles of “manufacturer” and “producer” merge in many cases, thereby increasing responsibility. Responsibility may shift within a supply chain: companies that were previously ‘only distributors’ or “only brand owners” may now be classified as producers – with full compliance obligations. 

You should check: 

• Do you place packaging or packaged products on the EU market for the first time? 
• Do you sell under your own brand or trademark? 
• Do you commission manufacturing or packaging through third parties? 
• Do you import packaged goods into the EU? 
• Do you operate an online shop targeting EU customers? 

If any of the above points apply, you may be the obligated manufacturer under PPWR. You will then need to assess your role in the supply chain.

What you need to do now: 

• Map your packaging flow across countries and partners. 
• Analyse design, recyclability, and minimisation requirements. 
• Prepare for EPR obligations in all relevant Member States. 
• Establish documentation and conformity processes early. 
• From 2026, compliance will no longer be optional — and the responsibility will be clearly assigned. 

Need Help With EU Packaging Compliance? 

The PPWR is reshaping responsibilities across the entire packaging value chain.
If you are unsure whether your company is considered a “producer” or how the regulation affects you, please contact us by answering 5 simple questions in our Quick Obligation Check. 

Fundamental Changes Are Ahead

The new EU Battery Regulation (Regulation (EU) 2023/1542), which has now completely replaced the previous directive with phased obligations until 2030, fundamentally changes the way batteries are designed, placed on the market, managed and recycled. One of the most important changes is the transition from three battery types under the old Battery Directive to five clearly defined battery categories. 

The new categories determine which compliance obligations apply to your products, what documentation you need, how you must label and collect them – and ultimately, how costly and complex your obligations will be. 

Why Did the EU Move From 3 to 5 Categories? 

The old Battery Directive (2006/66/EC) relied on three broad categories: 

• Portable batteries 
• Industrial batteries 
• Automotive batteries 

These categories were too vague for today’s market, where batteries are embedded in nearly every product – from e-bikes to wearables to vehicles powered by high-capacity lithium packs. The result was inconsistent interpretation across Member States and unclear obligations for manufacturers. 

The 5 Battery Categories Explained – and What They Mean For You 

By distinguishing between very different use cases – from AA batteries to EV packs – the law can now set the right technical and environmental requirements for each type. This harmonised structure reduces national discrepancies, supports safer and more sustainable battery life cycles, and reflects the rapid rise of e-mobility and consumer electronics. In short, the new categories adapt the regulation to today’s technological realities and future-proof the EU battery market. 

1. Portable batteries 

Definition: Sealed, lightweight batteries (< 5 kg) used by consumers in everyday devices such as remote controls, toys, kitchen appliances, laptops and smartphones. 

Update:
– Stricter requirements for replaceability (from 2027, most portable batteries must be easily removable by the user)
– Stricter collection targets (63% by 2027, 73% by 2030)
– Higher minimum proportion of recycled materials 

Affected businesses: Electronics manufacturers, importers and online sellers, as well as all brands offering battery-powered consumer products on the EU market. 

2. Batteries for light mobility devices (LMT) as a new category 

Definition: Batteries used to power e-bikes, e-scooters, hoverboards or similar vehicles. 

Update as new category: The LMT market has grown explosively and no longer fit into the “portable” or “industrial” categories. Safety, fire hazards, transport issues and end-of-life disposal required separate regulations. 

Impact on businesses:
– Requirements for performance and safety testing
– CO2 footprint information (phased)
– Specific collection and recycling obligations
– Manufacturers and importers of e-bikes/e-scooters now bear full EPR responsibility without restrictions 

3. Starter, lighting and ignition batteries (SLI batteries) 

Definition: Batteries mainly used in vehicles to start engines and supply power for lighting and ignition. 

Update:
– Clearer distinction from EV batteries
– Specific regulations for durability, safety and labelling 

Affected businesses: Automotive suppliers, automotive manufacturers, aftermarket brands. 

4. Industrial batteries 

Definition: Batteries for industrial or professional use or any batteries weighing more than 5 kg that do not fall under other categories.
Examples: Forklift batteries, batteries for telecommunications base stations, ESS (Energy storage systems). 

Impact on businesses:
– Requirements for performance, durability and sustainability
– Mandatory due diligence in the supply chain
– Stricter recycling and reporting requirements 

5. Electric Vehicle (EV) Batteries as another new category 

Definition: Drive batteries for electric or hybrid vehicles. 

Update as a new category: The carbon footprint of these EV batteries, material composition (lithium, cobalt, nickel) and recycling value differ fundamentally from SLI or industrial batteries. 

Impact on businesses:
– Mandatory CO2 footprint disclosures
– Quotas for recycled content
– Battery passport requirements (from 2026)
– Manufacturer responsibility for collection, take-back and proper treatment
– Manufacturers must prepare for extensive documentation and traceability requirements 

What Companies Need to Do Now 

1. Clearly identify your battery category: Review your product portfolio and assign each battery to the correct category.
2. Review your Extended Producer Responsibility (EPR) obligations: Your obligations may have changed or expanded significantly.
3. Prepare for new technical and sustainability requirements: These include information on carbon footprint, durability testing and the interchangeability of portable batteries.
4. Adapt your supply chain and documentation processes: This applies in particular to electric vehicle and industrial batteries, which require due diligence systems and battery passports.
5. Update your compliance strategy before the regulations come into force: Penalties will be high, and national authorities are preparing for stricter enforcement. 

If you have any questions or need assistance in assessing the impact of the new battery regulation on your business, our team at PRONEXA is here to help. Contact us!

For years, companies have viewed waste management as a cost factor. Collection targets, reporting requirements, recycling obligations. Under Extended Producer Responsibility (EPR), these were strictly viewed as compliance tasks rather than strategic opportunities. But something has changed. Quietly and steadily, a new paradigm is shifting governments’ view of waste and manufacturers can no longer afford to ignore it. 

Welcome to the age of urban mining, where yesterday’s discarded products become tomorrow’s competitive advantage in the supply chain. This shift is fully in line with the European Green Deal, which places the circular economy, resource efficiency and reduced dependence on fragile raw material imports at the heart of European industrial strategy. 

The Hidden ‘Mines’ in Our Cities 

Every laptop, every battery, every vehicle and every device contains metal and material deposits that are becoming increasingly difficult – and politically risky – to extract from nature. Cobalt from conflict zones, rare earths from geopolitically tense regions and critical raw materials tied to volatile global markets. 

But while the world worries about supply shortages, these very materials lie in our cities, waiting to be recycled. The richest mines are no longer underground, but in drawers, garages and recycling centres. This is the logic that shapes today’s waste regulations. The pressure to recycle is not only ecological, but also strategic. In other words, waste isn’t leaving your value chain. It’s coming back as a resource. 

How Urban Mining Is Practically Implemented 

Three changes are already underway: 

1. Eco-design: products designed for recycling 

Manufacturers are redesigning products so that they can be easily dismantled, sorted and recycled. What used to be considered a cost factor at the end of a product’s life is now becoming an opportunity for material recovery. 

2. Better collection and traceability 
With the introduction of digital product passports, return systems and more transparent collection channels, it will be possible to better track where valuable materials end up after use. This will ultimately enable companies to recover these materials more reliably and reintegrate them into production.

3. New cooperation models 

Producers, compliance systems and recycling companies are working more closely together than ever before. When they share data and plans, this leads to higher recovery rates, lower costs and more stable access to scarce materials. 

Why This Is Important for Companies Right Now 

Companies that still view waste solely as a compliance issue are missing the big picture. Urban mining is becoming an indispensable strategy for 

• reducing dependence on unstable global supply chains,
• lowering material costs, 
• achieving circular economy goals, and 
• strengthening brand and ESG performance. 

Working Together to Make Circularity Happen 

Together, both producers, PROs, and ourselves at PRONEXA can work more closely together to make the circular economy a reality and improve sustainability.

In case of any questions about Urban Mining, your contribution as a Producer and EPR in general contact us today!

Since the new EU Battery Regulation came into force in Mid-August, the industry has been buzzing: Manufacturers, importers, and distributors across Europe are now facing a wave of new obligations, unclear definitions, and unanswered questions. From the upcoming EU Battery Passport to new rules on recycled content, carbon footprint declarations, and sustainability design – with the new Battery Regulation the regulatory landscape is becoming more complex than ever.  
 
However, some things remain unchanged: If your electrical or electronic products contain batteries, you still have EPR obligations under both WEEE and Battery legislation. Still, this rule continues to surprise many companies. 

WEEE and Battery Means Dual EPR Responsibility 

We regularly receive inquiries from companies bringing Electrical and Electronic Equipment (EEE) onto the market in various EU countries, being uncertain on “Who is the producer?” They struggle with the differentiation of the “manufacturer” of the product and the role as “producers”, responsible under EPR legislation. While those companies often “only” ask for support on WEEE, we frequently find out during our intensive assessment that their WEEE products also contain batteries. Therefore – in addition to their WEEE EPR obligations – these companies are considered “producers” also for the batteries and are subject to the same obligations under Extended Producer Responsibility (EPR) rules  that the new regulation puts in place.

Here are some examples of electrical devices that you would not immediately suspect to contain batteries: 

• Computer motherboards:
  They contain a small button cell battery that supplies power to store settings (such as system time and configurations) even when the PC is turned off and
  disconnected from the power supply 

• Smart kitchen appliances with integrated rechargeable batteries 

• Electric toothbrushes or shavers with built-in power cells 

• IoT and smart home devices powered by button cells or small batteries 

• Cordless tools with lithium-ion packs 

• Children’s toys or gadgets with internal batteries 

Companies placing those products on the market must register both – as WEEE and a Battery producer. 

The Battery EPR Obligation Remains – Even Under the New Regulation 

While the new Battery Regulation introduces major changes – such as stricter sustainability criteria, collection targets and digital traceability – the core compliance duties remain fully intact: 

• Registration with the relevant authorities

• Reporting of batteries placed on the market 

• Take-back and recycling obligations 

• Labeling and documentation requirements

These foundational rules continue to apply, regardless of how the upcoming technical details on the Battery Passport or carbon footprint reporting evolve. 

Marketplaces Are Stepping Up Compliance Checks 

Another important development: Online marketplaces such as Amazon, eBay or Otto are increasingly required to verify the EPR compliance of all sellers. In practice, this means: 

• Without a valid Battery registration number, sellers cannot list their products

• Marketplaces perform automated compliance checks before listings go live

• Missing registrations can lead to sales bans or delistings almost instantly

• For small and mid-sized producers, this can quickly result in disruptions to sales channels or even penalties

What Producers Should Do Now 

If you’re a manufacturer or importer of electrical devices, take a moment to review your compliance setup: 

• Do your products contain batteries – even small or built-in ones? 

• Are you registered under the national Battery EPR scheme? 

• Are your volume reports and labeling up to date? 

• Can your products legally be sold via online marketplaces? 

Establishing a combined EPR strategy for WEEE, Batteries, and Packaging can prevent compliance gaps, duplicate filings, and unnecessary costs.

If you have any questions about BATT-EPR, please do not hesitate to contact us at PRONEXA. 

What Is Packaging Labelling? 

When it comes to packaging in Europe, labelling is more than just a design decision – it´s a legal and environmental responsibility. Across the EU and in key markets such as Germany, France, and Italy, regulations are evolving to ensure that consumers are informed about recycling and that sustainable waste management is promoted.  

The Basics: What Must Be On Your Packaging 

European regulations require packaging to contain information that helps consumers recycle properly and understand the materials used. This typically includes: 

• Brand and Product name 
• Recyclability information 
• Sorting instructions for end users 
• Material type 
  

The upcoming EU Packaging and Packaging Waste Regulation (PPWR) goes even further. Under the new regulations, packaging must include a QR code that is clearly visible, legible, and indelible. This QR code contains information on: 

• Material composition 
• Reusability 
• Instructions for separate collection / recycling 

A Brief Overview of EU Labelling Regulations 

• 1994: Introduction of the EU Packaging and Packaging Waste Directive. 
• 2018: Directive (EU) 2018/851 amended the regulations to reduce packaging waste. 
• From 2025: The PPWR will standardize labelling throughout the EU, with full implementation taking place in the following years. 

National Differences and Special Requirements for Packaging Labelling in the EU 

In general, responsibility for EU labelling regulations lies with the person who puts the goods on the market. Producers, importers and distributors are obliged to package the goods properly and label them in accordance with the regulations of the EU country. Retailers or third parties should ensure that the goods and packaging have already been correctly labeled by the upstream supplier. 

• Germany: No general legal labelling requirement, but specific requirements apply to export packaging. 
• France: Strict labelling regulations, especially for household packaging, including the Triman logo and sorting instructions. 
• Italy: Since 2023, all packaging must be marked with a numerical code and sorting information. 
• Spain: From 2025, household packaging must be clearly and legibly labeled.  
• Portugal: From 2025, the labelling of household packaging will be mandatory. 
• United Kingdom: No general obligation yet, but a new law is planned for 2027.  

While Germany and many other European countries often do not have mandatory packaging labelling regulations in accordance with EU requirements, other countries have introduced strict regulations. Future EU plans to tighten and standardize regulations could bring new challenges. 

The PPWR: What Will Change From 2025? 

The PPWR will introduce harmonized EU-wide labelling requirements, the final specifications of which are expected by mid-2026 and which are to apply in full from 2029. The new system will require the following: 

• Labelling of the material composition of the packaging to make it easier for consumers to sort. 
• Reusability indicators and a QR code or other digital label indicating reuse options and collection points. 
• Digital identification of hazardous substances (SVHCs) and their concentrations. 

New Challenges and Goals for Producers 

The transition to uniform EU labelling will simplify cross-border trade in the long term, but will lead to complexity in the short term. Until full harmonization is achieved, businesses will have to adapt to a patchwork of national regulations. For online retailers selling across borders, this means they will have to meet multiple compliance requirements simultaneously. 

While the aim of the PPWR is to limit differing national regulations in order to avoid trade barriers, some exceptions remain—for example, specific labelling requirements of member states to indicate participation in a national EPR system or a deposit- return-system.  

Meet Your Packaging Labelling Obligations in Europe 

From the French Triman logo to alphanumeric coding in Italy, the list of obligations can seem overwhelming. However, with the right expertise, compliance doesn’t have to be a burden. Our team of compliance specialists is happy to help you navigate packaging and product labelling regulations across Europe – tailored to your business and your market. 

Contact us right now!

If your business places packaging (e.g. packaged goods) on the market, understanding packaging types isn’t just good practice – it’s a legal requirement. At PRONEXA, we’re committed to helping our clients meet their compliance obligations under Extended Producer Responsibility (EPR) regulations, offering a One-Stop-Shop solution. Let’s break down the key concepts around packaging, what needs to be declared, and how you can manage your data effectively.

What Is Packaging?

Packaging includes any material used to contain, protect, handle, deliver or present goods. From raw materials to finished products, packaging ensures safe transportation and display – from steel tins and plastic wrap to pallets and cardboard boxes. It even includes items like cups, food containers, sandwich bags or others filled at the point of sale (service packaging).

Understanding what qualifies as packaging is the first step to staying compliant and sustainable.

The Three Main Types of Packaging

1. Primary Packaging – The Sales Packaging

This is the packaging that is used to contain a single ‘unit of sale’ for customers. For a sales unit made up of multiple items, such as a multipack, primary packaging includes all the packaging on the items.

Example:
A product paperboard carton with a paper label, or the small plastic film or bag around individual product units or bundles of product units in a multipack.

2. Secondary Packaging – The Grouped Packaging

Used to group multiple sales units together for transportation or display.

Example: 
A corrugated cardboard box that holds several units of product on a store or warehouse shelf.

3. Tertiary Packaging – The Transport Packaging

Tertiary or transport packaging grouping secondary packaging units together to protect them during transport or handling through the supply chain.

Example: 
Shrink wrap, steel bands or plastic wrap tape, and wooden pallets used to move  packaging units.

Types of Packaging Materials

If your company places packaged goods on the market, even internally or on behalf of another organization, you are likely responsible for reporting certain packaging types and materials.

Common materials to categorize and report include:

• Glass
• Paper/cardboard
• Plastic
• Ferrous metal
• Aluminium
• Wood
• Other and composite materials (e.g. textiles, ceramics, etc.)

Efficiently Managing Your Packaging Data

PRONEXA empowers businesses to take control of their packaging data through smart systems and collaborative solutions. If a company supplies packaging to the market and would like to entrust PRONEXA with the management of the packaging compliance, the following steps have to be taken:

• Records of packaging data must be kept.
• The quantities of packaging to be placed on the market per year must be calculated and estimated.

As a producer (any manufacturer, importer or distributor), you have various options to generate and manage your packaging data to comply with the Packaging and Packaging Waste Regulation (PPWR). This presents both challenges and opportunities – compliance will require investment, but companies that innovate early will gain a competitive advantage. Here´s how you can get there:

1. Internal Data Collection and Management

• Enterprise Resource Planning (ERP) Systems: 
  Many companies use ERP systems to track their goods movements. These systems can often be configured to also capture packaging data, such as material type, weight, and quantity.
• Excel Spreadsheets: 
  For smaller companies or as a transitional solution, Excel spreadsheets can be used to manually capture and manage packaging data. However, it is important to ensure that the data is consistently and accurately recorded.
• Specialized Packaging Software: 
  There are specialized software solutions tailored to managing packaging data. These solutions can automate data collection, analysis, and reporting.

2. Collaboration with Suppliers and Service Providers

• Supplier Information: 
  Request detailed information from your suppliers about the packaging they provide. This information can help you complete your own packaging data.
• Consulting: 
  Businesses hire a consulting firm as PRONEXA that is specialized in national packaging law and requirements. These firms can assist you with packaging data collection, and data analysis.
• Collective Schemes or PROs: 
  PROs often offer support with data collection and reporting. Utilize the resources and training provided by your dual system.

3. Technical Solutions

• Barcodes and RFID: 
  Use barcodes or RFID technology to automatically capture packaging data. This can improve the accuracy of data collection and reduce effort.
• Digital Documentation: 
  Use digital documentation to capture and process the data.

Accuracy Is Everything

Compliance with packaging regulations means precision. Inaccurate or incomplete data can lead to issues with the Packaging Regulation and national legislations or acts such as penalties, delays, or reputational damage. That’s why we always recommend:

• Accuracy:
  Ensuring the accurate collection and reporting of your packaging data
• Documentation:
  Keeping full documentation and audit trails
• Automation:
  Consider automating your data collection and reporting to reduce effort and improve accuracy 

The Solution: PRONEXA® Customer Data Management Platform
Managing packaging compliance requirements may seem complex. With our PRONEXA® Customer Data Management Platform your able to report your packaging data centralised and simple in one platform. You can simplify allocate your packaging data for every PRO and in every country.

Learn more about the PRONEXA® CDM Platform on our website or contact us directly via our Quick Obligation Check.

Why Is There a New Battery Regulation?

The old Battery Directive came into force in 2006. At that time, some batteries were not yet widely used in our daily lives, such as batteries for electric cars, e-bikes and e-scooters. In addition, there is a sharp increase in electrical devices such as smartphones, wireless headphones and laptops. This rapid increase in the use of different batteries prompted the EU to introduce the new Battery Regulation. On August 18, 2025, the key provisions of the new Battery Regulation (EU 2023/1542) will come into force in all EU member states, replacing the previous Battery Directive from 2006.

From a Directive to a Regulation – What Does That Mean?

The main difference between a directive and a regulation in EU law lies in their direct applicability and the degree of harmonisation. A regulation is directly applicable law in all member states, whereas a directive sets out objectives that the member states must implement through national legislation.
The fact that the EU has turned a directive into a regulation alone demonstrates the importance of this innovation.

What Will Change With the New Regulation?

The EU is pursuing several key objectives with the new Battery Regulation:

• Reduction of environmental impact
• Longer service life through better design
• Promotion of recycling and raw material recovery
• Harmonization in the EU internal market

New Classification of Battery Categories

As the number of (different) batteries has grown rapidly over the years, one of the biggest changes in the new Battery Ordinance is therefore the classification of battery categories.

In addition to portable batteries (≤5 kg), as found in household appliances, the regulation distinguishes between the following categories

• LMT batteries (≤25 kg): for light means of transportation such as e-scooters or e-bikes
• EV batteries (>25 kg): for hybrid and electric vehicles
• SLI batteries: for starting, lighting and ignition in vehicles and machines
• Industrial batteries (>5 kg): e.g. for communication, industry or agriculture
• Energy storage batteries (ESS): for stationary storage, often in combination with solar systems

The Most Important Requirements for Producers

1. Registration obligation & market surveillance
All manufacturers, importers and distributors (“producers” according to the law) must register in the respective EU member states and submit regular quantity reports. Stricter controls across the EU also apply – violations can lead to high fines or sales bans.

2. Labelling & Compliance Documentation
From the effective date onward, only batteries with specific labelling, e.g. QR codes or symbols, may be placed on the market.

3. Supply Chain Due Diligence
Companies with annual battery-related revenues exceeding €10 million must establish a due diligence system.

4. PRO and Collection Targets
By August 2025, companies must provide systems through which end users can return batteries free of charge.
The EU sets concrete collection targets:

• 63% for portable batteries by the end of 2027
• 51% for LMT batteries (e.g. e-bikes) by the end of 2028

5. Product Design & Recyclability
From 2027, batteries must be designed for easy removal and recyclability. Besides, the use of recycled raw materials (e.g., cobalt, lead, lithium) will be mandatory.

What Producers Have to Do Now

If your company is already registered with a recognized PRO (Producer Responsible Organisation) in the EU countries, where you sell your products, important basic requirements have been met. In this case, you have already integrated important EU requirements into your sustainability and recycling strategy and fulfil take-back, information and due diligence obligations.

If you are not registered with a PRO and/or need more information to better deal with the complexity of this new European Regulation, don’t hesitate to contact PRONEXA via our Quick Obligation Check. PRONEXA will support you on the correct allocation of your products, to meet your compliance obligations across all 30 European countries.